INTRODUCTION

If you use 4399 NET LIMITED (“we” or “us”) Applications versions other than the versions distributed in specific countries/regions includes Mainland China, Hong Kong, Macau, Taiwan, Japan and Korea, you acknowledge that you have read and understood this privacy policy. If you do not agree with this privacy policy (“this policy”), you must not use Company Services. If you change your mind in the future, you may withdraw your consent to use of your personal information in accordance with this policy.

This privacy policy is an inseparable part of our Terms and Service. This policy applies to all Company Services that directly reference or link to this policy but does not apply to Company Services that have separate privacy policies that do not incorporate this policy.

The minimum age to create a 4399 NET LIMITED Account ("Account") is 13. Insofar as certain countries or platforms apply a higher age of consent for the collection of personal data, 4399 NET LIMITED requires parental or guardian consent before an Account is created and personal data associated with it is collected.

You agree that if you are under whatever is the age of legal majority where you access the services, you represent that your legal guardian has read, understood, and agreed to this policy.

SECTION 1：WHAT DATA WE COLLECT AND PROCESS

1.Data We Collect and Process from You

a) Account Registration Information. Such as your username, email address, mobile phone number, password, verification code, age, gender, date of birth, photograph and/or other information that helps you create and manage the account for your use of our services.

b) Contact Information. Such as your address, Email address, telephone number and/or other location related information (geographical location, IP address, etc.);

c) Transaction information. Such as your bank/debit/credit card number, card expiration date, billing address (country, city, postal code, address), and CVV.

d) Marketing and communication data. Such as your advertising ID, your preferences for receiving marketing materials, your communication preferences, your communication history with us and our service providers and your survey content, comments and responses;

e) Sweepstakes participation Information. Such as your name, UID, email address, mobile phone number, nickname, country/region. Where you win any prizes, you may also need to provide us your mailing address for us to send you the prize. Your activity participation information may be added to your account.

f) Game Play Statistics. Such as your roles, heroes, character appearance, attributes (e.g., level, scores, experience points, and skills), progression and results, virtual currencies, item inventory, tasks and rewards, social connections within the Services, and chat/usage//transaction data.

2. Data We Collect From Other Sources

a) Social Media Information. Such as name/nickname/username as your use on social media account profile, profile pictures, social media account ID, associated email address and other social media profile information, including lists of friends on social media.

b) Location Information. Such as geographical location, IP address, ID and WiFi connection location.

c) Device Information. Such as application version, network type, operating system, MAC address, device identifiers, device model, device operating systems, regional and language settings, internet service provider, screen resolution, frame rate, ping value, stack information, server health indicators, date and time stamps of actions, advertising identifiers, gameplay events and events on thirdparty websites, including data obtained through cookies and similar technologies.

d) ThirdParty Payment Information. Such as a hashed identifier of your account with the third-party payment processing service, and the country/region from which your payment originated.

3. Cookies

We use cookies and other similar technologies (e.g., web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using our Services. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality. You may permit installation of such Cookies or subsequently disable them. You may accept all cookies, or instruct the device (in the case of the Game) to provide notice at the time of installation of cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event of your refusal to install cookies, the Game may be unable to operate as designed.

SECTION 2: WHY WE COLLECT AND PROCESS YOUR AFOREMENTIONED DATA

In order to better provide services to you, we and our affiliates may collect and process your aforementioned personal information and other relevant data for purposes including to:

a)allow you to access or restrict your access to our services;

b) provide you the services required by you and perform our contractual obligations towards you;

c) analyze and manage our services for system administration, user service, security, frauddetection, checking the authenticity of an account owner, archival and/or backup purposes;

d) correct bugs or errors, improve our services and respond to customer desires and preferences, including language and location customization, personalized support and instructions, and other responses;

e) develop new services or products and improve the user experience;

f) verify and confirm payment;

g) deliver advertising that may be relevant to your interests and track the success of our advertising and marketing programs to personalize your experience;

h) communicate with users (including by sending text messages and/or push notifications) and take action against violations;

i) keep you up to date with the latest product announcements, and provide other information pertaining to our services;

j) provide software verification, upgrades and administration, notify of special events;

k) offer to participate in our surveys or activities;

l) fulfill our obligations under applicable laws and regulations, respond to requests of government authorities;

m) establish, exercise or defend legal claims;

n) analyze, profile, segment, merge and/or update all collected data (regardless of an aggregated or individualized manner) for the purposes of improving service quality and providing a better experience;

o) protect the integrity, information safety, and financial security of our services or users, comply with legal obligations, and enforce compliance with the Terms of Service or other restrictions placed on your use of our services;

p) track your process across our websites and applications to verify that you are not a bot and to optimize our services; and/or

q) for any other purposes which are permissible under applicable law and which we notify you of at the time of obtaining your consent.

Such purposes may not be the case because the purposes for which we will collect/may collect, use, disclose or process your personal data depend on the circumstances at hand. However, unless Privacy Laws permit processing of applicable data without your consent, we will notify you of other purposes at the time we obtain your consent.

SECTION 3: LEGAL BASIS FOR OUR COLLECTING AND PROCESSING

We rely on a number of legal grounds to process information about you. For example, we will process information about you where we have your consent, where we have a legitimate interest to do so, where the processing is necessary for the performance of a contract with you, and where we have a legal obligation to process your information. For example, we rely on our legitimate interests to serve targeted marketing and on contractual necessity to process information when you create an account. To learn more about the legal grounds on which we rely to process your information for any particular purpose, please contact us via the options in Contact & Complaints below.

SECTION 4: HOW WE USE YOUR PERSONAL INFORMATION

1. Share. We value the protection of your personal information, which is an important basis and part of the products and services we provide to you. We will only collect and use your personal information for the purposes and within the scope of this Policy or as required by law and regulations and will keep it strictly confidential. In general, we will not share your personal information with any company, organization or individual, except in the following cases:

a) with your prior consent;

b) where the sharing of your personal information is required by applicable law, regulation, legal process, governmental compulsion or judicial decision;

c) to the extent required or permitted by law, it is necessary to provide your personal information to third parties in order to protect us, its users or the public from harm to their interests, property or safety;

d) your personal information may be shared among our affiliated companies. We will only share personal information that is necessary and such sharing is subject to the stated purposes of this Policy. If an affiliate wishes to change the purpose of processing personal information, it will again seek your authorized consent;

e) in order to provide you with improved, quality products and services, some of our Services will be provided by authorized partners. We may share some of your personal information with our partners in order to provide better customer service and user experience. We will only share your personal information for purposes that are legal, legitimate, necessary, specific, and explicit, and only as much personal information as is necessary to provide the services. We also require our partners to handle your personal information in accordance with our instructions, this Policy, and any other relevant confidentiality and security measures. Our partners are not authorized to use the personal information shared for any other purpose. If you refuse to allow our partners to collect the personal information necessary to provide the service, you may not be able to use that third party service on our platform.

Besides, such contractors may use cookies, web beacons, and/or other tracking technologies to collect or receive data about you and might claim data controller rights over your personal data. For example, users purchasing and/or subscribing to products or services will be required to provide additional data to thirdparty payment contractors, such as a valid credit card number and expiration date. Such third-party payment contractors may collect, process, and retain your data to process payments and resolve subsequent payment disputes and inquiries. We may also receive, process, and store the provided information from you and/or such third-party payment contractors to confirm payment, record purchase history, and/or protect our legitimate interest when resolving subsequent payment disputes and inquiries. Notwithstanding the foregoing, if you make any payments in using our services, any of your payment details are fully handled by the relevant payment service provider. We do not, however, receive and/or process any of your actual payment details such as your card number or security code. We only keep the data concerning transaction date, transaction order number, currency, cost, payment channel, and product(s) purchased.

Each thirdparty has its own privacy policy and security measures for processing data and information, so when specific third-parties are involved in collecting data and information, please participate in their privacy policies. Since those contractors may access, collect, or process your data as the data controller and operate under their own privacy policies, please refer directly to their privacy policies on their official websites and learn more about their data processing practices.

2. Transfer. We will not transfer your personal information to any company, organization or individual, except for the following:

a) Transferring with obtaining explicit consent: after obtaining your explicit consent, we will transfer your personal information to other parties;

b) Provision in accordance with applicable laws and regulations, requirements of legal proceedings, and mandatory administrative or judicial requirements as may be necessary;

c) In the event of a merger, acquisition, transfer of assets, bankruptcy and liquidation or similar transaction involving the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this Policy before we require the company or organization to seek your authorized consent again.

3. Disclosure. We will only disclose your personal information publicly when:

a) After obtaining your express consent;